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510(k) Data Aggregation

    K Number
    K172727
    Device Name
    Hemoclip
    Date Cleared
    2018-04-16

    (217 days)

    Product Code
    Regulation Number
    876.4400
    Reference & Predicate Devices
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The hemoclip is indicated for endoscopic clip placement within the gastrointestinal tract for the purpose of:

      1. Endoscopic marking
      1. Hemostasis for
    • · Mucosal/sub-mucosal defects <3cm
    • · Bleeding ulcers
    • · Arteries<2mm
    • Polyps<1.5cm in diameter
    • · Diverticula in the colon
    • · Prophylactic clipping to reduce the risk of delayed bleeding post lesion resection
      1. Anchoring to affix jejunal feeding tubes to the wall of the small bowel
      1. As a supplementary method, closure for GI tract luminal perforations<20mm that can be treated conservatively.
    Device Description

    The Hemoclip is a sterile device consisting of a pre-loaded, radiopaque, single-use, endoscopic clipping device consisting of two main components: the delivery system and the clip. The delivery system consists of a handle and delivery catheter. The delivery system is constructed using stainless steel, and polyester materials. The delivery system will allow for the device to rotate at the distal end. The delivery system is offered in 1650mm, 1950mm and 2300mm working lengths. The clip consists of a stainless steel capsule, and clip arms, a Cobalt Chrome Yoke, and a styrene tension breaker. The clip is deployed from the delivery system during use. The hemoclip jaws are engineered such that they can be opened and closed up to five times prior to deployment, aiding in repositioning of the clip at the lesion site. Re-opening, closing, and rotation capability may be limited by clinical circumstances and patient anatomy. There are no associated accessories included with this device.

    AI/ML Overview

    The provided document, a 510(k) Summary for the Hemoclip, does not contain information about acceptance criteria for device performance based on diagnostic metrics (e.g., sensitivity, specificity) derived from a study involving human readers or ground truth established by experts.

    Instead, this document focuses on establishing substantial equivalence for a medical device (Hemoclip) through a series of bench tests and comparison to predicate devices, without involving clinical trials or diagnostic performance studies in the way one might expect for AI/Software as a Medical Device (SaMD) clearances.

    Therefore, many of the requested categories cannot be answered from the provided text.

    Here's what can be extracted:

    1. A table of acceptance criteria and the reported device performance

    The document lists several bench tests that were performed. The acceptance criteria are implicitly "passing" for each test.

    Test NameAcceptance Criteria (Implicit)Reported Device Performance
    Open and ClosePassingPassing
    Clip releasing forcePassingPassing
    Clamping strengthPassingPassing
    Tensile StrengthPassingPassing
    Separation ForcePassingPassing
    Rotation propertyPassingPassing
    CorrosionPassingPassing
    AppearancePassingPassing
    SizePassingPassing

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    This information is not provided in the document. The tests mentioned are bench tests, not clinical studies involving patient data.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    This information is not applicable/provided. Ground truth by medical experts (e.g., radiologists) is typically established for diagnostic performance studies, which were not conducted for this device clearance.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    This information is not applicable/provided. Adjudication methods are typically used for establishing ground truth in clinical/diagnostic studies.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. The document explicitly states: "No Clinical test is included in this submission." This device is a mechanical medical instrument, not an AI/SaMD.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    No, a standalone performance study was not done. This device is a mechanical medical instrument, not an AI/SaMD.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    This information is not applicable/provided. The "ground truth" for the bench tests would be defined by engineering specifications and physical test standards (e.g., a force gauge measurement, a caliper measurement), not medical ground truths like pathology or expert consensus.

    8. The sample size for the training set

    This information is not applicable/provided. There is no mention of a "training set" as this device is not a machine learning or AI product.

    9. How the ground truth for the training set was established

    This information is not applicable/provided. There is no mention of a "training set" or its ground truth establishment.

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